Medical services and first aid

The employer must provide the medical services and first aid required by 1926.50. Employers must make sure that injured or ill employees receive prompt and effective first aid and access to medical services as required by that section.

• The duty in 1926.951(a) is an explicit cross-reference to the general medical services and first aid requirements in 1926.50, so you must follow the provisions of 1926.50 (for example, providing first-aid supplies, arrangements for medical care, and trained responders as required by that standard).

Persons with first-aid training must be available whenever employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, per 1926.951(b).

• This is an additional requirement on top of the general 1926.50 medical services and first-aid duties.

For field work involving two or more employees at a work location, at least two trained persons must be available, according to 1926.951(b)(1).

• Practically, that means a crew of two working in the field must ensure there are at least two persons present who have the required first-aid training; those two could be the two crew members themselves if both are trained.

A trained person must be able to physically reach any employee exposed to electric shock within four minutes at fixed work locations, per 1926.951(b)(2).

• Consider real-world travel time, gates, ladders, keys, access routes, and PPE removal time when assessing whether a trained responder can actually arrive and render aid within four minutes.
• If the layout or barriers prevent a responder from getting to an injured worker in 4 minutes, the employer must increase the number of trained persons or take other measures so the requirement is met.

If the existing number of employees is insufficient to meet the 4-minute reach requirement at a fixed location (for example, a remote substation), each employee at the work location must be a trained employee, as stated in 1926.951(b)(2).

• In practice, that means the lone worker must have first-aid training so that no one dependent on an outside responder fails the 4-minute reach criterion.

No, 1926.951 itself does not list a specific curriculum or number of hours for first-aid training; it requires that persons with first-aid training be available. Employers must ensure their trained persons are adequately trained to provide appropriate first aid for the hazards present and must follow the general 1926.50 requirements for medical services and first aid.

• For life-saving skills such as CPR and AED use, OSHA recognizes best practices and has issued guidance addressing CPR retraining and the role of CPR training in workplace first-aid programs; see OSHA's interpretation on CPR retraining at https://www.osha.gov/laws-regs/standardinterpretations/2023-02-23 for further context on training frequency and expectations.

Yes, employers must provide first-aid supplies and arrangements as required by 1926.50, which is the standard referenced by 1926.951(a).

• The exact contents and type of first-aid supplies depend on the hazards, number of employees, and workplace circumstances, so follow the guidance in 1926.50 and applicable best practices to determine and maintain appropriate supplies.

No, the additional first-aid training rule in 1926.951(b) applies specifically when employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more.

• For work on equipment energized below 50 volts, employers still must comply with the general medical services and first-aid duties of 1926.50, but the special 50-volt-or-more training provisions do not apply.

Yes, 1926.951(b)(1) requires that for field work involving two or more employees at a work location, at least two trained persons be available. That is the minimum; employers may choose to have more trained responders when crew size, hazards, or site layout make that prudent.

• Even though two is the minimum, evaluate response times, site distance, and the nature of tasks to decide if additional trained personnel are needed.

You must provide a sufficient number of trained persons so that any employee exposed to electric shock can be reached within four minutes, per 1926.951(b)(2).

• To determine the number, consider: layout and distance between workers, obstacles (fences, locked gates), travel routes, time to don or remove PPE, available communications, and multiple simultaneous incidents.
• Document your assessment showing how you calculated response times and justify the number of trained persons you assign.

If the absence of a trained person means an exposed employee cannot be reached within four minutes at a fixed location, the employer would not meet the requirement in 1926.951(b)(2).

• Employers should plan coverage so trained responders are always available (e.g., overlapping shifts, backup responders, remote-worker training) and must take corrective action (increase trained personnel or change work arrangements) to maintain compliance.

The standards referenced in 1926.951(a) direct employers to provide medical services and first aid as required in 1926.50, but they do not universally require an on-site physician or nurse for every site.

• Whether a medical professional is required depends on the hazards, number of employees, and applicable specific standards; where a particular construction standard requires onsite medical personnel, that requirement applies. In many cases employers meet the requirement by having trained responders, first-aid supplies, and arrangements for prompt access to medical care.

Relying only on external emergency services may not satisfy 1926.951(b) if those services cannot reach the injured worker within the required time frame.

• For field work with two or more employees, 1926.951(b)(1) requires at least two trained persons at the location itself.
• For fixed locations, if EMS cannot provide assistance within 4 minutes to every exposed employee, the employer must provide enough trained personnel on site (or train all employees) so the 4-minute reach requirement is met, per 1926.951(b)(2).

1926.951 does not itself specify recordkeeping requirements for first-aid training, but employers should maintain documentation to demonstrate compliance with the training and availability requirements in 1926.50 and 1926.951.

• Good practice is to keep training certificates, dates, instructor information, and a schedule for refresher training. Documentation helps show that trained persons were available and appropriately qualified when needed.

Yes, 1926.951(b) covers persons performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, so workers who are associated with energized lines (for example, crew members working nearby or assisting) fall within the requirement and must have access to trained first-aid persons per the section's field and fixed-location rules.

• Employers should evaluate all workers who may be exposed to electric shock hazards (not just those doing electrical tasks) and provide appropriate coverage.

OSHA does not mandate a specific retraining interval for CPR in [1926.951], but OSHA's guidance supports annual instructor-led retraining for life-threatening emergency skills such as CPR and AED use. See OSHA's interpretation on CPR retraining at https://www.osha.gov/laws-regs/standardinterpretations/2023-02-23 for more detail.

• While 1926.951 requires trained persons for work on energized lines, employers should follow recognized best practices (e.g., annual retraining) to ensure responders remain competent and able to render effective aid.